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Metropolitan Taxicab Board of Trade v. City of New York

Filing Date: 2008
Case Categories:
  • Federal Statutory Claims
    • Clean Air Act
      • Industry Lawsuits
        • State and Municipal Vehicle Standards
Principal Laws:
Clean Air Act (CAA), Energy Policy and Conservation Act (EPCA)
Description: Challenge on preemption grounds to New York City regulations intended to increase fuel efficiency of taxi fleet.
  • City of New York v. Metropolitan Taxicab Board of Trade
    Docket number(s): 10-618
    Court/Admin Entity: U.S.
    Case Documents:
    Filing Date Type File Action Taken Summary
    02/28/2011 Order Order issued denying certiorari. The Supreme Court denied a request by New York City to review a Second Circuit decision that blocked enforcement of city regulations requiring taxicab owners to convert to an all-hybrid fleet.
    11/05/2010 Petition for Writ of Certiorari Download Petition for writ of certiorari filed.
  • Metropolitan Taxicab Board of Trade v. City of New York
    Docket number(s): 09-2901-cv
    Court/Admin Entity: 2d Cir.
    Case Documents:
    Filing Date Type File Action Taken Summary
    07/27/2010 Opinion Download Opinion issued. On appeal, the Second Circuit affirmed, holding that the rules “relate” to fuel economy standards as that term is understood in statutory construction. The court found that imposing reduced lease caps solely on the basis of whether or not a vehicle has a hybrid engine has no relation to an end other than an improvement in fuel economy. Thus, it was preempted by EPCA. Because the court found that it was preempted by EPCA, it did not reach the  issue of whether it was also preempted under the CAA.
  • Metropolitan Taxicab Board of Trade v. City of New York
    Docket number(s): 08-7837
    Court/Admin Entity: S.D.N.Y.
    Case Documents:
    Filing Date Type File Action Taken Summary
    06/22/2009 Opinion and Order Download Opinion and order issued. In March 2009, New York City adopted a package of incentives to encourage taxicab owners to convert to all-hybrid fleets. The incentives had been designed as an alternative to city fuel efficiency rules for taxis struck down earlier by a federal district court on federal preemption grounds. To encourage the purchase of hybrid vehicles, the alternative plan relied on incentives in City lease cap rules rather than miles-per-gallon fuel efficiency standards. The fleet owners and a trade association filed an action in federal court alleging that the rules that reduced the lease caps for non-hybrid, non-clean diesel vehicles constituted a mandate that was preempted by the Energy Policy and Conservation Act (EPCA) and the CAA. In June 2009, the district court granted a motion for a preliminary injunction blocking the incentive plan, holding that the new rules amounted to a de facto mandate to purchase hybrid vehicles and thus they were related to fuel economy and preempted under the EPCA and the CAA.
    09/08/2008 Complaint Complaint filed.

© 2023 · Sabin Center for Climate Change Law · U.S. Litigation Chart made in collaboration with Arnold & Porter Kaye Scholer LLP

The materials on this website are intended to provide a general summary of the law and do not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.